Everybody Chiropractic is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. Everybody Chiropractic may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from 4th October 2018.
Everybody Chiropractic Clinic patient privacy statement.
Everybody Chiropractic Clinic aware of its obligations under the General Data Protection Regulation (GDPR) and is committed to protecting the privacy and security of your personal information. This privacy notice describes, in line with GDPR, how we collect and use personal data about you during and after your time as a patient of this clinic. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to current and former patients.
Data controller details
This Everybody Chiropractic Clinic is a data controller, meaning that it determines the processes to be used when using your personal data. Our contact details are as follows: Everybody Chiropractic, unit 1, Kingfisher Court, Northfields Farm Lane, Witney, OX281UE. Tel: 01993 772 552. Email: firstname.lastname@example.org
Data protection principles
In relation to your personal data, we will comply with data protection law. This says that the personal information we hold about you must be:
processed fairly, lawfully and in a clear, transparent way collected only for valid reasons that we find proper for the course of your time as a patient and not used in any way that is incompatible with those purposes only used in the way that we have told you about accurate and up to date kept only as long as is necessary for the purposes we outline process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed kept securely
Types of information we hold about you
Personal data or information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed. We hold many types of data about you, including:
your personal details including your name, address, date of birth, email address, phone numbers gender marital status next of kin and their contact numbers personal medical or health information, including past medical history
information concerning examination and treatment at your first and subsequent visits letters of referral to or from the clinic regarding your treatment with us.
Special categories of data
There are "special categories" of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation. The only data we collect on this is in regards: Health
We do not store data on sexual orientation etc.
We will use your special category data:
1. to ensure the care you receive at the clinic is appropriate to your condition
2. to determine reasonable adjustments that should be made for access to the clinic or to treatment
We must process special categories of data in accordance with more stringent guidelines. We will process special categories of data when the following applies:
1. you have given explicit consent to the processing on our (New Patient consent form)
2. we must process the data in order to carry out our legal obligations
3. we must process data for reasons of substantial public interest
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
As with all cases of seeking consent from you, you will have full control over your decision to give or withhold consent and there will be no consequences where consent is withheld. Consent, once given, may be withdrawn at any time. There will be no consequences where consent is withdrawn.
How we collect your data
We collect data about you in a variety of ways and this will usually start when you make an enquiry to the clinic and continue when you attend your first and subsequent appointments. At this clinic, we keep electronic records. Information we write down on paper may be transferred to our electronic system. We may receive information about you from your GP or other health care provider regarding your referral or, with your permission, additional information that will help us continue with your treatment. We may also hold the results of tests that you have undertaken and that are relevant to your treatment with the clinic.
Personal data is kept in the clinic in a variety of forms. We store your data in the following ways:
Electronic notes:We use a clinic management software package to manage your personal data, treatment records and any letters/communications. This software is firewall protected and all back-ups encrypted. A second back-up is performed to a cloud-based server off-site which is also encrypted. Access to this system is by individualised password login only. Access is limited to staff, practitioners and third-party practitioners who need access to the system in order to complete their role as a practitioner. The software management company also have access. Our software management company and third-party practitioners are all GDPR compliant and data processor contracts are in place.
All our computer systems are username and password protected. We have multi-level firewall security in place.
Why we process your data (How we will use information about you)
The law on data protection allows us to process your data for certain reasons only, these are classified as legitimate interests. Most commonly, we will use your personal information in the following circumstances:
in order for us to carry out our contract with you (your requesting treatment and our agreement to provide it constitutes a contract) which will include confirming appointments, informing you of changes to appointments or clinic arrangements, changes to facilities or services at the clinic.
in order to provide you with the best possible treatment by recording health and treatment information which would be in your best interest.
in order to carry out legally required duties such as those required by us by our government appointed regulator.
where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests
We may use your personal information in these rare situations:
where we need to protect your or someone else’s interests
where it is needed in the public interest or for official purposes
Situations in which we will use your personal information
We need all the categories of information to primarily allow us to perform our contract of treatment with you and to enable us to comply with legal obligations.
If you do not provide your data to us
One of the reasons for processing your data is to allow us to carry out our duties in line with your contract of care with us. If you do not provide us with the data needed to do this, we will be unable to perform that care to ensure your best interests are being maintained. We may also be prevented from continuing with your treatment with us due to our legal obligations.
Change of purpose
We will only use your personal information for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Automated decision making
No decision will be made about you solely on the basis of automated decision making (where a decision is taken about you using an electronic system without human involvement) which has a significant impact on you.
Sharing your data
Your data will be shared with colleagues within the Clinic but only where it is necessary for them to undertake their duties. This includes, for example, other chiropractors working for, at or on behalf of the clinic, reception staff, practice manager and massage therapists.
We may share your data with third parties in order to facilitate a referral to another healthcare practitioner, investigation or to keep your GP informed about your progress with treatment. Third parties that process data on our behalf include:
•Jonas Cunningham: Self-employed Chiropractor - data used for providing treatment/care.
•Alex Dowmus: Self-employed Massage Therapist - data used for providing treatment/care.
•Cliniko– Clinic management software
•Clinic Answer – virtual service for appointment reminders (Access address, phone number & email address only).
•rehabmypatient – Online exercise programme (Access limited to name and email address only)
We may also share your data with third parties as part of a Clinic sale or restructure, or for other reasons to comply with a legal obligation upon us. We would always keep you informed of these situations.
Transferring information outside the EU
We do not share your data with bodies outside of the European Economic Area.
Data Security - Protecting your data
We have put in place measures to protect the security of your information against accidental loss or disclosure, alteration, unauthorised access, destruction or abuse. We have implemented processes to guard against such. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. Details regarding data security is freely available to patients. Please enquire and we would be happy to share our Information & Data security Audits with you at a mutually convenient time.
Where we share your data with third parties, we provide written instructions to them to ensure that your data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of your data.
How long we keep your data for
In line with data protection principles, we only keep your data for as long as we need it for, which will be at least for the duration of your being a patient with us and we are legally required, by the Chiropractic regulator, to keep this data for eight years after your time as a patient has ended. To determine any appropriate retention period for personal data beyond eight years we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
Once we no longer have a lawful use for retaining your information, we will dispose of it in a secure manner that maintains data security.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your time as a patient with us.
Your rights in relation to your data
The law on data protection gives you certain rights in relation to the data we hold on you.
The right of access.
You have the right to access the data that we hold on you. To do so, you should make a subject access request. Find out how to do this from Dr Jonas Cunningham (Clinic Director).
The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you can require us to correct it.
The right to be informed.
This means that we must tell you how we use your data, and this is the purpose of this privacy notice. We also must inform you of any changes to how we use your data.
The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it. However, if it falls under our legal obligation to keep your data securely for a longer period we will do so.
The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct.
The right to portability.
You may request transfer of the data that we hold on you for your own purposes.
If you want to access your data, review, verify or correct your data, request we erase your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact our reception staff via email on email@example.com or in writing to Everybody Chiropractic, unit 1, Kingfisher Court, Northfields Farm Lane, Witney, OX281UE, and this request will be passed onto the clinic director to be reviewed. The clinic director will then contact you in writing/email.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee for a second or subsequent copy of information, for a summarised version/report or if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Right to withdraw consent
Where you have provided consent to the collection, processing and transfer of your data, you have the right to withdraw that consent at any time. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate legal reason for doing so.
To withdraw consent, contact Philip Jones via email on firstname.lastname@example.org or in writing to Everybody Chiropractic, unit 1, Kingfisher Court, Northfields Farm Lane, Witney, OX281UE, and this request will be passed onto the clinic director to be reviewed. The clinic director will then contact you in writing/email.
Making a complaint
If you have any questions about this Privacy Notice or how we handle your information, please contact the Clinic’s Data Protection Manager who is the Clinic Director (Dr Jonas Cunningham). They can be contacted on 01993 772 552, via email on email@example.com or in writing to Everybody Chiropractic, unit 1, Kingfisher Court, Northfields Farm Lane, Witney, OX281UE, and this request will be passed onto the clinic director. The clinic director will then contact you in writing/email.
You have the right to make a complaint at any time to the supervisory authority in the UK for data protection matters, the Information Commissioner’s Office (ICO).
Welcome to Everybody Chiropractic’s privacy notice.
Everybody Chiropractic clinics respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Everybody Chiropractic clinics collect and process your personal data through your use of this website, including any data you may provide through this website, for example when you contact us or sign up to our newsletter.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Everybody Chiropractic is the controller and responsible for your personal data (collectively referred to as "Everybody Chiropractic", "we", "us" or "our" in this privacy notice).
Everybody Chiropractic Clinics operate the websites: www.everybodychiropractic.co.uk.. We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Name: Everybody Chiropractic clinics Everybody Chiropractic, unit 1, Kingfisher Court, Northfields Farm Lane, Witney, OX281UE. (Head Office)
Name or title of Data Privacy Manager: Jonas cunningham
Email address: firstname.lastname@example.org
Telephone Number: 01993 772 552
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated in June 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
·Identity Data includes first name, last name.
·Contact Data includes email address.
·Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
·Usage Data includes information about how you use our website.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
·Direct interactions. You may give us your Identity and Contact Data by contacting us or requesting marketing to be sent to you;
·Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
·Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
·Identity and Contact Data from competition organisers who collect your data when you enter a competition to win a stay in a Scott Williams villa.
·Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks based inside or outside the EU; and
(c) search information providers based inside or outside the EU.[LE3]
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
1. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.
2. Where you have given us consent
Consent means that you have given us clear consent for us to process your data for a specific purpose. You have the right to withdraw consent to marketing at any time by contacting us.
3. Where we need to comply with a legal or regulatory obligation.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Purposes for which we will use your personal data
1. Legitimate interests
We rely on the legitimate interest basis to process your data in the following circumstances:
·To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
This is necessary for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or a restructuring exercise.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
This is necessary to study how individuals use our website, to develop our website, to grow our business and to inform our strategy.
To use data analytics to improve our website, services, marketing, users relationships and experiences.
This is necessary to define types of users for our services, to keep our website updated and relevant, to develop and inform our strategy.
·To respond to queries made through the website
This is necessary to be able to provide you with a response to your query.
We rely on your consent to process your data in the following circumstances
• To send you marketing material when you have signed up to receive our newsletter.
3. Legal or regulatory obligation
We also rely on the legal or regulatory obligation ground to process your data in some circumstances. This means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Please contact us if you would like more details about the specific legal ground we are relying on to process your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase.
For more information about the cookies we use, please see our Cookies Policy on our website.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in paragraph 4 above.
External Third Parties:
Service providers based in UK who provide IT, system administration services and e-marketing on the Everybody Chiropractic’s behalf.
Professional advisers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
We do not transfer your personal data outside the European Economic Area (EEA).
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
i. Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
ii. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
iii. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
iv. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
v. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
vi. Request the transfer of your personal information to another party.
vii. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you want to exercise any of the above rights, please contact Data Privacy Manager in writing.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
Introduction to Cookies
Cookies are small files stored in your browser and are used by most websites to help personalise your web experience. Some features on this site may not function if you do not allow cookies.
For additional information on cookies please check out the Information Commissioner's Office.
If you accept cookies the following cookies may be set on your device:
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Third Party Cookies
We use a number of tools and external applications, in particular Google Analytics, Google Maps and Google Custom Search, to enhance visitor interaction on our site. These services will set a cookie called 'PREF' which Google uses to track user preferences from one site to another.
These cookies are used on some sites when completing online forms, logging in to the site or using other functions. They do not contain any personal information and for the most part are automatically deleted when you close your browser.
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Details of cookies used by this website
This list shows all cookies used by this website, and what each is used for.
Cookie Name Purpose Expiry
__utmb Google Analytics cookie. This stores the domain name (hash code) of site, pages viewed this session, current time. 30 minutes
__utmc Google Analytics cookie. This stores the domain name (hash code) of site. At end of session
__utma Google Analytics cookie. This stores the domain name (hash code) of site, a unique visitor id (randomly generated number), time of first visit, time of previous visit, current time, number of sessions since first visit. 2 years
__utmz Google Analytics cookie. This stores the domain name (hash code) of site, time when cookie last set, total number of visitor sessions, number of different channels or sources through which this site was reached, source of the last cookie update, search hit tag identifier (or just 'organic' if reached via normal search hit), search medium, keyword phrase used to find site. 6 months
PREF Saves the user's Google identifier, time of first receiving this cookie, last time when preferences were set, checksum for data integrity. This third-party cookie is placed by Google to track a user's preferences from one Google site to another 2 years
Links to other websites
Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your Personal Information
You may choose to restrict the collection or use of your personal information in the following ways: whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at email@example.com We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.